This Management Bulletin provides a series of questions and answers
from the United States Department of Agriculture (USDA) regarding
reimbursement for meals served in special schools or institutions
that do not participate in the National School Lunch Program (NSLP)
or School Breakfast Program (SBP).

Questions and Answers

When a public school district places students in special
schools or institutions, hereafter called "pupil placement," are the meals served to those students eligible for reimbursement?

Yes, but only if the school that serves students
the meal is an eligible site and participates in the NSLP
and/or SBP.

Note: A placement school, home district, or another participating
school may not claim reimbursement for a meal if the school
serving the meal is not eligible or chooses not to participate
in the NSLP and/or SBP. This applies even when the home district
or another school participating in the NSLP and/or SBP provides
the meal to an ineligible school, which then serves
the meal to a child.

What is an "eligible" school?

The Richard B. Russell National School Lunch Act [42
U.S.C. 1760(d)(3)], the Child Nutrition Act of 1966 [42 U.S.C.
1784(3)], and NSLP and SBP regulations [7 CFR 210.2 and 220.2]
define an "eligible" school as any public or non-profit
private school of high school grade or under and any public
or licensed nonprofit private residential child care institution.
For a school and/or institution to be eligible, the California
Department of Education must recognize it as part of California’s
educational system. A "for-profit" school/institution
is not eligible to participate in the NSLP and/or SBP.

What is "pupil placement?"

Pupil placement is when a public school district contracts
with an outside school to provide necessary educational services
unavailable within the district for a particular student.
For example, a public school district may place a student
with discipline problems in an alternative school or a student
with a disability in a specialized school.

Pupil placement is when a public school district contracts
with an outside school to provide necessary educational services
unavailable within the district for a particular student.
For example, a public school district may place a student
with discipline problems in an alternative school or a student
with a disability in a specialized school.

Are there special considerations for "pupil placement" for students with disabilities?

No. As previously stated, the school or district may claim reimbursement
for meals only when the school that serves the meal to the student
participates in the NSLP and/or SBP.

Are there any provisions that accommodate off-site
consumption?

Yes. USDA’s Food and Nutrition Service Instruction FNS
786-8, Revision 1, provides citations describing when a participating
school may claim meals for reimbursement for off-site consumption.
These situations are limited to meals served on supervised field
trips and work-study programs. The home school or district cannot
provide and claim a sack lunch everyday for a student in pupil
placement at a nonparticipating or ineligible school.

What alternatives should schools or districts consider
for students placed in nonparticipating NSLP and/or SBP schools?

If a school district places students in a school not
participating in the NSLP and/or SBP, the district may wish
to expand its contract to include the cost of providing meals
for its students in pupil placement. However, such meals are
not reimbursable under the NSLP and/or SBP.

Please share this bulletin with your district/agency management
and business personnel as appropriate.